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of Difference between assessed income and returned income arose due to inadvertent error in taking opening written down value (WDV) at book value instead of WDV under Income Tax Act. First Appellate Authority deleted penalty u/s 270A based on Prem Brothers Infrastructure LLP case, holding bona fide error cannot be basis for penalty. Revenue's appeal dismissed, Tribunal affirmed deletion of penalty, stating human error cannot invite penalty imposition.
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